Free Motion for Extension of Time to File Response/Reply - District Court of Federal Claims - federal

Case 1:06-cv-00382-LB

Document 12

Filed 12/07/2006

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LAW OFFICE OF CHRISTINE M.WEAVER, P.S. PLAINTIFF'S MOTION FOR ENLARGEMENT OF TIME - 1
9011 E. Valleyway Ave. Spokane Valley, WA 99212 TEL: (509) 924-5181 FAX: (509) 924-3403

IN THE UNITED STATES COURT OF FEDERAL CLAIMS *** ANNETTE BUEHLER, v. THE UNITED STATES NO. 06-382 C Judge Lawrence J. Block

PLAINTIFF'S MOTION FOR ENLARGEMENT OF TIME *** Pursuant to Rule 6(b)(1) of the Rules of the United States Court of Federal Claims (RCFC), Plaintiff, Annette Buehler, respectfully requests a 30 day enlargement of time, through and including January 31, 2007, within which to file her response to the Defendant's Motion to Dismiss. Her response is currently due January 1, 2007. This is Plaintiff's first request for an enlargement of time for this purpose. Plaintiff's counsel has corresponded with Defense counsel and Defense counsel will not be objecting to this request. The enlargement is requested for two reasons. First, the current deadline for Plaintiff's response is New Year's Day making the actual due date January 2, 2007. The various holidays immediately preceding the due date will lessen the amount of time for Plaintiff to file her response. Second, Plaintiff's counsel will be undergoing knee surgery on December 15, 2006, that will require her to be away from her office through January 1, 2007. Combined, these two situations will make it extremely difficult for Plaintiff and her counsel to file the response to Defendant's Motion to Dismiss.

Case 1:06-cv-00382-LB

Document 12

Filed 12/07/2006

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For these reasons, Plaintiff respectfully requests that the Court grant this Motion for Enlargement of Time. DATED: December 7, 2006. LAW OFFICE OF CHRISTINE M. WEAVER, P.S. By: s/ Christine M. Weaver CHRISTINE M. WEAVER Attorney for Plaintiff Law Office of Christine M. Weaver, P.S. 9011 E. Valleyway Ave. Spokane Valley, WA 99212 (509) 924-5181

LAW OFFICE OF CHRISTINE M.WEAVER, P.S. PLAINTIFF'S MOTION FOR ENLARGEMENT OF TIME - 2
9011 E. Valleyway Ave. Spokane Valley, WA 99212 TEL: (509) 924-5181 FAX: (509) 924-3403

Case 1:06-cv-00382-LB

Document 12

Filed 12/07/2006

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CERTIFICATE OF SERVICE I hereby certify that on December 7, 2006, I electronically filed the foregoing with the Clerk of the Court using the CM/ECF System, which will send notification of such filing to the following, and/or I caused to be served a true and correct copy of the foregoing on the following in the manner indicated below: Claudia Burke Department of Justice Civil Division 1100 L St. N.W. Room 11058 Washington, D.C. 20530 XX Electronically U.S. Mail Overnight Mail Hand Delivery Facsimile

s/ Christine M. Weaver CHRISTINE M. WEAVER

X:\04-1009\PLD G \CO U RT OF FEDERAL CLAIM S \ENLARGE-TIME.W PD

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LAW OFFICE OF CHRISTINE M.WEAVER, P.S. PLAINTIFF'S MOTION FOR ENLARGEMENT OF TIME - 3
9011 E. Valleyway Ave. Spokane Valley, WA 99212 TEL: (509) 924-5181 FAX: (509) 924-3403